The Federal Emergency Management Agency (FEMA) has announced a revision to the State Mitigation Plan Review Guide that will require State Hazard Mitigation Plans (SHMP) submitted on March 2016 and beyond to address climate change.
States must have a FEMA-approved SHMP in order to receive federal disaster mitigation funding from FEMA. Such plans require gubernatorial approval, after which they are sent to FEMA for final consideration. In order for a SHMP to be approved by FEMA, the new guidance requires the risk assessment to address climate change:
a. The risk assessment must provide a summary of the probability of future hazard events that includes projected changes in occurrences for each natural hazard in terms of location, extent, intensity, frequency, and/or duration
b. Probability must include considerations of changing future conditions, including the effects of long-term changes in weather patterns and climate on the identified hazards
Some states already address climate change in their plans, including California and Connecticut, yet many states that receive a substantial portion of the hazard mitigation funding from FEMA do not (e.g., Florida and Texas) because the 2008 guidance did not require climate change to be considered. In a recent report by Columbia Law School, 18 states either do not mention or dismiss climate change in their SHMP . The new guidance puts FEMA at odds with several high profile governors including Chris Christie of New Jersey, Greg Abbott of Texas and Bobby Jindal of Louisiana, who have repeatedly denied man-made climate change and/or refused to take action . In a statement to the Washington Times, Bobby Jindal blasted the Obama Administration for playing hard ball with vital disaster preparedness funds, “The White House should not use it for political leverage to force acquiescence to their left-wing ideology” . In contrast, environmental advocates are heralding FEMA’s assertive new guidance as an important step by the agency to address climate change in its operations. However, according to Adam Sobel, director of Columbia University’s Initiative on Extreme Weather and Climate, the new guidance could have gone further, “They’re [FEMA] saying, ‘You have to account for climate change, but you have total freedom in how to do that’… It sounds like it’s a pretty lax standard” . FEMA’s push to require states to address climate change is a result of Obama Administration policy directives, preparedness goals, mitigation frameworks and executive orders that emphasize the need to address climate change in policy actions.
FEMA asserts the new guidance t is based on an interpretation from FEMA’s Climate Change Adaptation Policy (2011-OPPA-01), which directs FEMA programs and policies to incorporate considerations of climate change adaptation. The policy does not affect a state’s eligibility to receive federal money for relief after a hurricane, flood or other disaster.
While the plans must consider climate change in assessing future risk, FEMA has given the states little guidance as to how they should address climate change in a SHMP. According to the new guidance, FEMA recommends states “look across the whole community of partners (for example, public, private, academic, non-governmental, etc.) to identify the most relevant data and select the most appropriate methodologies to assess risks and vulnerability” . Although the National Resources Defense Council (NRDC) had petitioned FEMA to require states to offer an opportunity for public input on their draft plans prior to submitting them to the agency for approval, FEMA did not include this requirement in the revised guidance.
- More information on the State Mitigation Plan Review Guide is available through FEMA.
An Issue Brief Prepared by
Noah Hersch, Public Policy Fellow
Warwick Group Consultants, LLC